Retiring to Spain vs Portugal: A US Citizen’s Visa & Finance Guide

For many Americans, the question isn’t if they’ll retire to Europe, but where.

This definitive guide dives deep into the choice of retiring to Spain vs Portugal from a US citizen’s perspective.

We break down the financial requirements of Spain’s Non-Lucrative Visa and Portugal’s D7 Visa, compare the minimum stay rules, and—most importantly—provide expert strategies for managing your US-based investments, pensions, and Social Security abroad.

Get the clarity you need to plan your transatlantic retirement with financial confidence.

Retiring to Spain vs Portugal A US Citizen's Visa & Finance Guide - main image
Table of Contents

Introduction

American retirees are increasingly choosing Iberia for their next chapter, and the numbers back it up. In Spain, there are now roughly 41,000 U.S. citizens on the municipal rolls, while in Portugal, the U.S. community has surged to nearly 21,000.

But while these neighbours share sun-drenched coastlines and a relaxed pace of life, the paths to residency—and the financial planning required—are distinctly different.

This guide is designed to help Americans considering the move across the Atlantic, navigate that choice, moving beyond the lifestyle appeal to the financial realities of a transatlantic retirement.

What You'll Learn in This Guide

  • A detailed breakdown of Spain’s Non-Lucrative Visa (NLV) and Portugal’s D7 Visa.

  • The key benefits and potential drawbacks of each residency path.

  • A crucial explanation of the minimum stay requirements for maintaining residency.

  • A side-by-side comparison table of the most important financial and practical differences.

  • Expert financial strategies for managing your US assets and taxes from abroad.

  • An actionable checklist to start your planning process.

Option 1: Retiring to Spain with the Non-Lucrative Visa

Retiring to Spain vs Portugal A US Citizens Visa Finance Guide Beautiful Spain

The Spanish NLV is designed for individuals who have sufficient funds to support themselves (and their family) without needing to work in Spain. It’s often favoured by retirees with substantial savings or a high, reliable passive income.

Financial Requirements: Understanding the IPREM

Spain (NLV): Applicants must prove sufficient means equal to 400% of the IPREM benchmark for the main applicant (plus 100% per dependent). This benchmark, the Indicador Público de Renta de Efectos Múltiples, is a national standard used for various grants and visas.

  • The Calculation: For 2025, the monthly IPREM is €600. The calculation is €600 x 400% x 12 months = €28,800 per year for the main applicant. You must add 100% of the IPREM (€7,200) for each dependent.

  • Proof of Funds: This is a key difference from Portugal. Spanish consulates often want to see the full year’s amount sitting as a liquid balance in your bank account, proven with certified statements. You must also prove the ongoing nature of your income through pension letters, Social Security statements, and investment portfolio summaries. 

Health Insurance, Application, and Residency Path

Health Insurance: You must secure and pre-pay for a full year of private Spanish health insurance from an insurer authorised in Spain. The policy must offer coverage equivalent to the public system, with no co-pays or deductibles.
Find Spanish health insurance cover with PCC Insurance.

Application Process: You apply in person at the Spanish consulate with jurisdiction over your US state of residence. You cannot apply from within Spain. The initial visa is valid for 90 days, allowing you to travel to Spain and apply for your residency card (TIE). Find out more about the difference between the NIE and TIE in Spain.

Residency Path: The initial residency is for one year, followed by two renewals of two years each. After five years, you can apply for permanent residency.

Key Practical Steps

Beyond the finances, you will also need to provide a medical certificate confirming you are free of any diseases that could pose a public health threat, and a clean criminal background check from the FBI and any country you have lived in for the past five years.

Option 2: Retiring to Portugal with the D7 Visa

Retiring to Spain vs Portugal A US Citizen's Visa & Finance Guide - Beautiful Portugal

The D7 is often called the “passive income” or “retiree” visa. It’s ideal for those who can demonstrate a consistent, recurring stream of income from pensions, investments, rentals, or Social Security, even if the total amount is more modest than what’s required for Spain.

Financial Requirements: Demonstrating Passive Income

Portugal (D7): Retirees demonstrate predictable passive income (pension, rentals, dividends) roughly aligned with the Portuguese minimum wage level.

The Calculation: Based on the 2025 minimum wage of €820/month, the primary applicant must show 100% of this amount, which is €9,840 per year. You must add 50% for a spouse (€4,920/year) and 30% per dependent child (€2,952/year).

Proof of Funds: Portugal prioritises the regularity of your passive income. You will need pension award letters, Social Security statements, and dividend statements. While not a strict rule, it is highly recommended to open a Portuguese bank account and deposit a stable balance (typically €10,000 – €20,000) to show a buffer for your first year. Find out more about “the means of subsistence” in Portugal here.

Health Insurance, Application, and Residency Path

Health Insurance: For the initial visa application, you only need travel health insurance that covers you for at least four months with a minimum of €30,000 in coverage. Once you are a resident, you will be able to register with the Portuguese National Health Service (SNS).

Application Process: You apply via the designated visa processing centre (e.g., VFS Global) in your US consular jurisdiction. The initial visa is valid for four months, allowing you to enter Portugal and attend an appointment with the immigration agency (AIMA) to receive your residency permit.

The Residency Path: The initial residency permit is typically valid for two years, followed by a renewal for three years. A major advantage of Portugal is that after five years of legal residency, you can apply for both permanent residency and Portuguese citizenship, although recent changes in regulation are making citizenship requests increasingly challenging. Find out more about these changes here.

Key Practical Steps

The application will require a clean criminal background check from the FBI.

A crucial early step is obtaining a Portuguese NIF (tax number) and opening a local bank account, which is necessary to sign a lease and prove you have sufficient funds in the country.

A Critical Difference: Minimum Stay Requirements Explained

This is a crucial lifestyle and tax consideration. To maintain and renew your residency, you must not be absent from the country for extended periods.

  • In Spain: To renew the NLV, you cannot be outside of Spain for more than six months in any given year. This also generally makes you a tax resident.

 

  • In Portugal: The rule is slightly more flexible. You cannot be absent for more than six consecutive months or eight non-consecutive months within the duration of your residency permit.

Spain NLV vs. Portugal D7: Key Differences at a Glance

While the specific documentation can be complex, a high-level comparison helps to clarify the fundamental differences in financial thresholds, healthcare, and long-term benefits.

Here’s how the two visas stack up on the most critical points for American retirees.

FeatureSpain (Non-Lucrative Visa)Portugal (D7 Visa)PCC’s Takeaway
Annual Income (Single)~€28,800~€9,840Portugal has a much lower entry threshold.
Focus of ProofLarge liquid savings balance + incomeRegular, predictable passive income streamYour financial profile dictates the better choice.
Healthcare RequirementFull private policy, paid 1-year upfrontInitial travel insurance, then access to SNSSpain’s upfront cost is significantly higher.
Path to Citizenship10 years (with exceptions)5 yearsPortugal offers one of the fastest paths in the EU.

Planning on Retiring in Spain or Portugal?

Beyond the Visa: Expert Financial Strategies for Your Move Abroad

Cross-border retirement isn’t just about getting a visa, it’s about sequencing your assets, minimizing taxes, and preserving lifetime income in two (sometimes three) jurisdictions.

Building a Resilient Euro-Denominated Budget

Your US-dollar-based retirement funds will now need to cover euro-based expenses.

Build a 12 – 18 month cash flow that comfortably exceeds the thresholds in euros, account for exchange-rate swings, pre-fund private medical cover.

This means creating a budget with a significant buffer to absorb currency fluctuations without affecting your lifestyle.

Optimising Social Security and Pensions

For Social Security concerns, the U.S. has totalization agreements with both Spain (effective 1988) and Portugal (effective 1989).

These treaties can help you avoid paying Social Security taxes twice and allow you to combine coverage credits to qualify for benefits.

In short, you can usually keep receiving U.S. Social Security while resident in Spain or Portugal.

Structuring Tax-Efficient Retirement Account Drawdowns

When it comes to Pensions and IRAs/401(k)s, the U.S.-Spain and U.S.-Portugal income tax treaties coordinate which country gets taxing rights over pension income and help relieve double taxation (generally via foreign tax credits).

Your exact liability will hinge on residency status and treaty articles specific to private pensions and annuities, so coordinating drawdown timing and withholding is essential. We already have a dedicated article on how to move to Portugal with your 401k here.

" Many US retirees are surprised to learn that while they can claim Foreign Tax Credits to avoid double taxation, the timing of their income and the structure of their investment accounts can lead to unexpected tax liabilities in their first few years in Spain or Portugal. Planning your drawdown strategy before you become a tax resident is one of the most critical steps. "
Matthew Makowski
Director of Network Development Location: Spain

Portugal-Specific Tax Considerations

Portugal has adjusted preferential regimes in recent years; many retirees now face progressive Portuguese rates on foreign pensions unless a special regime applies.

Plan for potential Portuguese tax on U.S. pension distributions and model credits on your U.S. return.

Finally, the raw tax figure is multiplied by a coefficient based on the beneficiary’s kinship group and pre-existing wealth. This can increase the final bill significantly, especially for Groups III and IV.

Frequently Asked Questions (FAQs)

Do I have to pay taxes in both the US and my new host country?

Not necessarily on the same income.

As a US citizen, you must file a US tax return regardless of where you live.

However, due to the tax treaties with Spain and Portugal, you can typically claim a Foreign Tax Credit on your US return for taxes paid to your host country.

The goal is to avoid double taxation, but proper structuring is essential. This is one of the most complex areas of cross-border retirement.

Yes, but it can be complicated.

Many US brokerage firms have restrictions on serving clients with foreign addresses.

It’s vital to have a conversation with your financial institutions before your move and work with a wealth manager who specialises in cross-border clients to ensure you don’t face a sudden account closure or trading restrictions.

There’s no single answer.

The Spanish NLV is often better suited for those with high net worth and significant liquid savings.

The Portuguese D7 is generally more accessible for those with a steady, predictable retirement income, even if it’s more modest.

The best choice depends entirely on your personal financial profile and long-term goals.

No.

This is a common misconception. While proof of accommodation is required, simply buying a house does not grant you the right to live in either country.

You must qualify for a residency visa, like the NLV or D7, separately.

No.

While perfect for retirees, these visas are open to anyone with sufficient passive income or savings.

This can include investors with large dividend portfolios, landlords with rental income, or younger individuals with trust funds.

Your Retirement Checklist

Feeling prepared to move forward? Use this checklist to organise your next actions.

  • Assess your passive income streams and liquid savings.

  • Compare your financial profile against the NLV and D7 requirements.

  • Request up-to-date, certified statements for all pension and investment accounts.

  • Research private health insurance options for Spain.

  • Schedule a consultation with Private Client Consultancy advisor to model your cross-border tax situation and financial plan.

The Next Step to Retiring to Spain vs Portugal: A Call With A Private Client Consultancy Wealth Manager.

Choosing between Spain and Portugal involves more than just meeting the visa thresholds. It requires building a resilient financial plan that accounts for exchange-rate swings, pre-funding private medical cover, and structuring tax-efficient drawdowns from your US retirement accounts.

If you are considering Spain or Portugal for retirement, ensuring your financial house is in order is the first step. PCC Wealth helps U.S. retirees build euro-denominated budgets that clear visa thresholds with buffers and structure their portfolios for the long term.

A well-planned transition allows you to focus on the sun and culture, knowing the numbers are taken care of.

Contact us today for a complimentary discussion.

We’ve Moved Offices on 1st August 2025!

Private Client Consultancy is excited to announce that we have moved to a brand-new office space, designed to better serve our clients and reflect our continued growth.

Effective Date: Friday, 1st August 2025
New Address: Urb Jazmin De Miraflores, C. Jazmín, 2, Mijas Costa 29649, Malaga, Spain
Our phone numbers and email addresses remain unchanged.

All in-person meetings scheduled from 1st August onwards will take place at our new location. Please update your records accordingly.

We look forward to welcoming you to our new space!

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